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What's slithering at London City Hall? Background on the Reptilia Zoo

The information presented in this blog solely reflects the opinion of the author, supported by facts and references. Brendon Samuels is the coordinator of Bird Friendly London and a PhD candidate in the Department of Biology at Western University, where he previously served on the Western Animal Care Committee overseeing use of animals in research. Brendon acts at the Chair of the City of London Environmental Stewardship and Action Community Advisory Committee. He has extensive experience working in the pet industry and with exotic birds in captivity.

Beloved birds like the Northern Cardinal are close relatives of reptiles like the crocodiles kept at the Reptilia Zoo, sharing a common ancestor that lived ~240 million years ago.

Normally, we at Bird Friendly London focus on the feathered residents of our city. Today, in the interest of compassion and public education, I'm going to expand on that.

Did you know that, technically speaking, all birds are reptiles? According to the phylogenetic system that biologists use to classify organisms based on their evolutionary relatedness, birds are part of the clade Diapsida, which also includes all other living reptiles (crocodilians, turtles, tuataras, and squamates like lizards and snakes). You can learn more about it from Wikipedia. So, with that connection in mind, let's talk a little about what's happening in our Reptile Friendly City.

You may have seen recent headlines (e.g., CBC, CTV, LFPress) about an ongoing debate at London City Hall, specifically the Community and Protective Services (CAPS) committee, regarding a proposal to open a Reptilia Zoo at Westmount Shopping Centre on Wonderland Road. The reason for the debate is that the City of London's Animal Control By-law effectively bans private zoos that display exotic species, and Reptilia is seeking an exemption.

This is not a new proposal. The previous City Council received and denied a similar request for a by-law exemption from Reptilia back in 2018, but Reptilia didn't stop there. They obtained a building permit in 2021 to construct a facility for their zoo, now set to open in January 2023 at Westmount Shopping Centre. Ontario provincial licensing regulations allow them to operate a zoo with native reptile species. London's Animal Control By-law only applies to exotic/non-native species like alligators or Komodo dragons; London City Council can't stop Reptilia from running their business with native species unless there are animal welfare issues. Now, in the first month of the new Council, Reptilia has returned to ask for a by-law exemption again.

Some new City Councillors recognize an opportunity through Reptilia to create economic benefits and recreational possibilities for Londoners. I think we can all get behind those values. Supporting small businesses is a huge community focus in London, and making our fast-growing city more fun for residents and tourists is a great initiative. But, in the interest of making a well-rounded decision, maybe there are other things City Council should consider.

Let's think about risk, an important lens for all Council decisions. What risks would a Reptilia Zoo pose a) to the City of London and people who live here, and b) to the live animals that would be kept at Reptilia?

The City of London historically does not allow exotic zoos within City limits. Why? Putting aside ethical debates about the merits and shortcomings of businesses like Marineland or Ontario's various roadside zoos, the City has limited capacity to enforce its by-laws that would apply to those types of businesses. For instance, the City's Animal Control By-law is enforced mostly on a reactive, complaint-driven basis, with available staff resources spread pretty thin. If something goes wrong, it's up to the public to submit a complaint, and in some cases, to provide supporting evidence within a short window of time so an investigation can be launched. If a by-law infarction occurs at a private business, say on the part of staff that are capable of covering up evidence, it is unlikely that authorities would ever find out.

Susan Stevenson, representing Ward 4, seems to have appointed herself the Council spokesperson for granting Reptilia a by-law exemption. In her words, "if it's good enough for Vaughan and Whitby, why isn't it good enough for London"? Author's note: Reptilia was not "good enough" for Toronto or St Catharines. What Susan and other Councillors should be considering, beyond the positions of select other municipalities that have made decisions on permitting, is what expert authorities that oversee this industry have to say about Reptilia.

Canada's Association of Zoos and Aquariums (CAZA) is a non-profit organization representing the country’s leading zoological parks and aquariums. CAZA offers accreditation standards for quality animal care and welfare that are recognized as among the best in the world. Governments at all levels have incorporated CAZA standards into their regulatory frameworks either directly, by making CAZA accreditation a requirement for licensing, or by referencing them in their regulations.

Reptilia was previously accredited by CAZA, but their accreditation was revoked in 2021 after they failed to pass an inspection. When asked by CBC London, CAZA would not give details about why the accreditation of Reptilia was revoked, citing confidentiality reasons. Without this third-party accreditation, and given that City of London by-law enforcement lacks human resources with necessary expertise on the welfare of exotic animals like reptiles, there would be little capacity for future oversight of operations at Reptilia. Should London City Council promote an exotic zoo business while it is no longer recognized by authorities as upholding standards for animal welfare?

Suppose that Reptilia's longtime wish comes true in 2023, and they get permission to open up shop in London. With one by-law exemption granted, will other businesses capable of putting animals and people at risk become eligible to follow suit? How would Londoners feel about hosting new locations for African Lion Safari or Jungle Cat World, two Ontario zoos recently accused of violating international guidelines for animal safety? How would the City of London respond to a lion, or a kangaroo, or a massive python being accidentally let loose? What happens when predatory exotic animals kept in captivity harm or kill each other, or endanger their keepers and members of the public?

The risks associated with the City's decision about Reptilia carry implications beyond practicalities of enforcing by-laws or ensuring human safety. Regarding the consequences, Councillor Susan Stevenson has more to say:

Let that statement sink in: "City Council was not elected to make moral judgements".

If Susan doesn't think it's her job to make moral judgements through her work as a City Councillor, knowing that Council decisions impact Londoners, I would question if Ward 4's (also, incidentally, my own) elected representative truly grasps the gravity of her responsibility. Is Susan really leaving her moral compass at home whenever she weighs in at Council meetings? How should morality inform the work of municipal government? I hope someone finds an opportunity to ask her these questions.

Council's decision whether or not to grant an exemption to Reptilia is absolutely one that should be justified in moral terms, or more specifically, in the ethics of our government's approach to regulating the keeping of exotic animals in captivity. It can be difficult for people to recognize what is at stake, given how unfamiliar most of the general public and municipal decision makers are with reptiles. At the risk of anthropomorphizing (applying human characteristics to other animals), how do we empathize with a turtle or a crocodile, or learn to appreciate their intrinsic value and rights as different species? Why should we?

The jury is still out on similarities and differences between the brains of humans and reptiles, but a variety of evidence suggests that there is a lot more we share in common than was previously believed. We know with certainty that reptiles experience fear and aggression, and there is indirect evidence that they experience pleasure too. What can we learn from reptilian life history? While some species lay eggs and abandon their young before they hatch, others like crocodiles provide maternal care, where the mother assists hatchlings by transporting them in her mouth from the nest to the water, and may stay with her young for up to several months. Many reptiles like turtles display a variety of prosocial behaviours and seem to thrive in the wild as part of groups, even ones containing multiple species. We have only scratched the surface of understanding the inner worlds of reptiles, but what's already clear is that their lives are complex, and their presence on our planet is special and worth protecting.

Left: Crocodile mothers can be extremely gentle while transporting their young in their mouths. Right: A Spiny Softshell Turtle and Northern Map Turtle (both species at risk) basking on a log together in the Thames River in London.

For all the hype about reptiles in the local news, there's nothing being said about the ones we already have in London. In fact, numerous species of reptiles are indigenous to Ontario, and can be enjoyed by Londoners in our Environmentally Significant Areas (check out photographs and historical records from the community science platform iNaturalist).

Sadly, many species, including most of Ontario's turtles, are now at risk of extinction, partly as a result of historic conservation management decisions made by local and provincial governments. In London, some of the leading threats for reptiles include predation by pets, collisions with vehicles, habitat loss associated with new development (especially loss of wetlands), environmental pollution, invasive species, and deliberate killing by humans. Native reptiles may not provide immediate economic benefits we can measure, but their continued existence in London is pretty important for the food web and maintaining the vitality of our natural heritage – which does have measurable economic value.

If current and future generations of Londoners will continue to be able to enjoy reptiles that belong here, instead of exotics confined to cages and condemned for life to be at the mercy of paying customers, maybe City Council should consider other ways to promote Reptilia (the class of organisms) instead of a questionable zoo business that most people don't want.

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